Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Validity of reopening of assessment - Approval of PCIT u/s 151 - The Tribunal acknowledged the Assessee's argument regarding the mechanical approval granted by the PCIT. They referred to precedents where similar approvals were deemed invalid due to lack of meaningful application of mind. Citing relevant case law, the Tribunal concluded that the approval in this case, given with a simple "Yes, I am satisfied," lacked due application of mind by the approving authority. Therefore, the Tribunal allowed the ground raised by the Assessee regarding the validity of the reassessment proceedings.
Validity of reopening of assessment - Approval of PCIT u/s 151 - The Tribunal acknowledged the Assessee's argument regarding the mechanical approval granted by the PCIT. They referred to precedents where similar approvals were deemed invalid due to lack of meaningful application of mind. Citing relevant case law, the Tribunal concluded that the approval in this case, given with a simple "Yes, I am satisfied," lacked due application of mind by the approving authority. Therefore, the Tribunal allowed the ground raised by the Assessee regarding the validity of the reassessment proceedings.
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